ARLINGTON, Va.–NAFCU is encouraging NCUA to provide credit unions with the option to submit anonymous self-assessments as part of the agency’s request for comment on the collection of information related to the final interagency policy statement on diversity policies and practices.
That option, said NAFCU, encourages increased participation and candor.
Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) requires the directors of the Offices of Minority and Women Inclusion (OMWI) at NCUA and five other federal financial regulators to develop joint standards for assessing their regulated entities’ diversity policies and practices. As a result, on June 10, 2015, the agencies published a final policy statement establishing those standards. At the same time, NCUA released a Letter to Credit Unions (15-CU-05), which detailed the finalized standards and provided a sample voluntary self-assessment checklist. For credit unions the process is entirely voluntary.
“While NAFCU and its member credit unions acknowledge the joint agency’s efforts to develop straightforward and relatively concise forms, NAFCU has concerns over the additional burden that may result after a credit union chooses to voluntarily submit a self-assessment to NCUA,” said NAFCU in its letter, which was signed by Alexander Monterrubio, regulatory affairs counsel. “As stated in the Letter to Credit Unions, each year NCUA will request that credit unions voluntarily submit self-assessments so that the agency may aggregate the data to be used in its annual OMWI report to Congress. NCUA notes that any credit union electing to submit diversity information is permitted to designate such information as confidential. However, if a member of the public requests the information from NCUA under the Freedom of Information Act (FOIA), then the agency will be required to notify the credit union of the request and provide an opportunity for the credit union to substantiate its position that the material should be withheld. This process creates a situation where a credit union could potentially have its volunteered information released to the public.
“NAFCU believes that in order to enhance the quality, utility, and clarity of the information collection” and “minimize the … burden on respondents’ credit unions should be given the option to submit information anonymously, not just confidentially,” NAFCU continued in its letter. “For example, a credit union could instead be allowed to classify itself through generalized categories such as approximated asset size, number of employees, and geographic location. Such a policy would permit credit unions to freely submit information to NCUA while completely avoiding any negative consequences in the examination process or public exposure of sensitive information. In fact, if an option to provide anonymous information is provided, then the minimized risk is likely to encourage more credit unions to voluntarily submit self-assessments and create a more accurate picture of the industry.